DOJ-OGR-00004730.jpg

724 KB

Extraction Summary

5
People
2
Organizations
2
Locations
4
Events
3
Relationships
0
Quotes

Document Information

Type: Legal document
File Size: 724 KB
Summary

This legal document, filed on May 25, 2021, details the discovery provided by the Government to the defense in a case involving Epstein and Minor Victim-4. The evidence includes seized message pads, phone records, Federal Express shipment records, and flight records related to Epstein, his employees, and Minor Victim-4, all pertaining to charges in Counts Five and Six. The document indicates that further details about abuse and interactions will come from witness testimony, focusing on approximate timeframes due to the events occurring over a decade ago.

People (5)

Name Role Context
Epstein Defendant
message pads seized from Epstein’s Palm Beach residence; shipment from Epstein’s address in New York; flight records ...
Minor Victim-4 Victim
charges relate specifically to Minor Victim-4; messages left by Minor Victim-4; calls made by another Epstein employe...
Epstein employee Employee
calls made by another Epstein employee to Minor Victim-4; Epstein, the defendant, and other employees traveled
witness Witness
will come from witness testimony
three minor victims Victims
Similar to the other three minor victims referenced in the S2 Indictment

Organizations (2)

Name Type Context
Government government agency
Government’s theory of the case; Government provided the defense; Government has identified; Government has also prov...
Federal Express company
Federal Express records reflecting a shipment

Timeline (4 events)

2021-05-25
The S2 Indictment was returned, and the Government provided discovery to the defense.
Government defense
Witness testimony will provide details regarding specifics of abuse and interactions, focusing on approximate time periods rather than specific dates.
witnesses
during the period charged in Counts Five and Six
Portions of message pads were seized from Epstein’s Palm Beach residence.
Epstein’s Palm Beach residence
during the period charged in Counts Five and Six
Epstein, the defendant, and other employees traveled to and from Palm Beach on Epstein's private plane.
Palm Beach
Epstein Epstein employees

Locations (2)

Location Context
Epstein’s Palm Beach residence; traveled to and from Palm Beach
Epstein’s address in New York

Relationships (3)

Epstein defendant-victim Minor Victim-4
Charges in Counts Five and Six relate specifically to Minor Victim-4; evidence includes messages, phone calls, shipments, and photographs involving both parties.
Epstein employer-employee Epstein employee
An Epstein employee made calls to Minor Victim-4; Epstein and other employees traveled together.
Government prosecution-defendant Epstein
The Government is presenting its theory of the case and providing discovery to the defense regarding charges against Epstein.

Full Extracted Text

Complete text extracted from the document (2,105 characters)

Case 1:20-cr-00330-PAE Document 295 Filed 05/25/21 Page 23 of 26
detail as to the Government’s theory of the case and the nature of the proof that will underlie the
charges at trial”).
Moreover, the discovery in this case has provided the defense with even more information
regarding the charges contained in Counts Five and Six, thus providing another basis on which to
deny this motion. To assist the defense in reviewing this discovery, the same day that the S2
Indictment was returned, the Government provided the defense with a list of particular Bates
ranges that relate specifically to Minor Victim-4 and the charges contained in Counts Five and Six.
As a result, the Government has identified particularly relevant pieces of evidence regarding these
charges for the defense. (See Dkt. No. 188 at 3-4). This evidence includes, among other things,
portions of message pads seized from Epstein’s Palm Beach residence referencing messages left
by Minor Victim-4 during the period charged in Counts Five and Six; phone records reflecting
calls made by another Epstein employee to Minor Victim-4; Federal Express records reflecting a
shipment from Epstein’s address in New York to Minor Victim-4; and contemporary photographs
of Minor Victim-4. The Government has also provided the defense with Minor Victim-4’s birth
month and year. Additionally, the defense has flight records for Epstein’s private plane, reflecting
when Epstein, the defendant, and other employees traveled to and from Palm Beach on the plane
during the period charged in Counts Five and Six. In other words, the discovery provides the
defendant with more than sufficient information about Minor Victim-4 to permit her to prepare for
trial.
Similar to the other three minor victims referenced in the S2 Indictment, any remaining
detail regarding the specifics of abuse and particular interactions will come from witness
testimony. As is to be expected when describing events more than a decade in the past, that
testimony will provide approximate time periods when events occurred, rather than specific dates.
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DOJ-OGR-00004730

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